Letter on the Lack of Systematic Sampling of Cow Brains for BSE

As you know, Americans are understandably concerned about the possibility of mad cow disease or bovine spongiform encephalopathy (BSE) occurring in this country. Having witnessed the public health, social and economic devastation wrought by the disease in Europe, they are anxious not to see similar scenarios occur here. While there have been no cases of either BSE or its human equivalent, variant Creutzfeldt-Jakob disease (vCJD), in this country, over 100 people, primarily in Europe, have been diagnosed with vCJD and most of them have already died.

One line of defense is surveillance: systematic sampling by the USDA of cow brains from around the country. In the accompanying report, Public Citizen and the Government Accountability Project examine the current U.S. surveillance system for BSE. Our premise was that, because there is no reason to expect BSE to be significantly more likely to appear in one part of the country or another, testing rates should be approximately equal in all states.

We used data from the USDA to compare the bovine testing rates between states for the period August 1997-December 2000. There was a 400- to 2,000-fold difference between the states with the highest and lowest testing rates. Attempts to adjust for the age of the cattle slaughtered or their feed do not account for the massive variations in testing rates between states.

Based on these findings, the report made five recommendations:

Increase the transparency of the testing

Develop clear criteria for the selection of animals for testing

Randomly select slaughterhouses for testing of downer cattle

Monitor state testing rates to identify states with low rates

Conduct unannounced inspections to monitor compliance with the testing requirements

Please review the attached report and indicate whether and how you plan to order compliance with our recommendations. We are willing to meet with you to discuss them further.

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